Why Did My EMR Go Up With No New Claims?

Find the factor on both proposals and match it to the issued document for the relevant effective date. A premium increase can happen even when the factor stays the same. California’s insurance department describes a calculation that also involves classification rates, payroll and other rating adjustments; a changed invoice is therefore not evidence that the EMR changed. California Department of Insurance workers’ compensation guide.

Write down three separate comparisons:

Comparison	What to record	What it helps establish
Issued factor	Prior factor, new factor and each effective date	Whether the actual rating changed
Rating basis	Payroll or other exposure, classifications and applicable rates	Whether the underlying premium basis changed
Final proposal	Credits, debits, fees and other listed adjustments	Whether something outside the mod changed

Check notation too. A factor of 1.05 and a percentage of 105% describe the same numerical multiplier; they are not two different results. Do not compare a future estimate to last year’s final worksheet without labeling that difference.

For the policy’s benefits and scope, use the workers’ compensation coverage guide. The mod is a pricing input, not an explanation of everything the policy covers.

In NCCI’s standard annual-policy example, a January 1, 2026 mod generally uses policies beginning in 2022, 2023 and 2024. At the next annual renewal, the oldest policy leaves and a newer one enters. The current policy is not simply inserted as soon as an injury-free year ends. Short policies and changed renewal dates can produce different patterns. NCCI’s ABCs of Experience Rating, experience-period example.

That timing offers a possible explanation for the apparent contradiction: your quiet recent year may not yet be represented. Meanwhile, an older policy with reported claims may have entered the rating. Treat this as a hypothesis until the worksheets confirm it.

Create a small policy-period map with four columns: policy start, policy end, included in the old mod, and included in the new mod. Flag every row that entered or left. Ask your insurance professional to identify which policy-period change mattered and whether a comparison holding the other inputs constant is available.

Do not use the NCCI example as a nationwide calendar. California ties its experience-period window to the rating effective date and policy inception dates. Washington L&I uses its own experience-rating system. Confirm the actual plan before deciding when an old injury should disappear from the calculation. WCIRB experience-period explanation, Washington L&I experience rating.

No newly reported injury does not mean every existing claim stayed unchanged. WCIRB explains that insurers report payroll and losses through unit statistical reports, and claim reporting includes an estimate of present and future value. Ask whether an older claim’s reported value changed between the reporting dates used for the two ratings. WCIRB unit statistical report guidance.

Request loss runs that identify their valuation dates. A loss run is a claims-history report from the insurer; its preparation date and the values used for a rating may differ. Compare like dates where possible, and ask the insurer to reconcile the difference where they do not.

For each unexplained change, record the claim reference, earlier reported amount, later amount, valuation dates and the insurer’s explanation. Keep medical records and employee details in the insurer’s secure process rather than attaching them to a general renewal email.

An open claim is not automatically an error. Nor does closing a claim automatically erase the reported loss. The useful question is: “Which value belongs in this calculation under the applicable reporting and revision rules?”

Experience rating compares reported losses with an expected-loss benchmark. WCIRB explains that the benchmark reflects the business’s classifications and payroll. Its worksheet also groups payroll by the year a policy began, which may differ from the calendar year in your accounting report. WCIRB experience modification explanation, WCIRB experience-rating form.

Look for changes in the mix of operations, payroll allocated to each classification and the expected-loss inputs. Do not assume that “total payroll went down” necessarily means “the mod should go down.” The comparison involves more than that one number, and the outcome needs to be explained through the applicable formula.

Hypothetical document review: A painting contractor’s accountant compares a calendar-year payroll total with a worksheet organized by policies that begin in October. The totals differ. Before calling it a bureau error, the accountant rebuilds the payroll report for the policy periods and separates office and field operations using the insurer’s classification instructions. This example shows a reconciliation method; it does not predict a modifier or premium saving.

Ask for corrections to inaccurate records, rather than selecting a classification because its name sounds cheaper. Retain audit statements and descriptions of the actual work supporting each question.

A rating can change after missing or corrected records arrive. In California, WCIRB describes how unaudited payroll may be excluded and how a later insurer correction containing audited payroll can make the modification subject to revision. That is a specific reporting issue, separate from whether another injury occurred. WCIRB explanation of why payroll reporting matters.

Check the worksheet for an explanatory status, notation or revision date. Ask whether the older number was missing a policy, used an estimate or preceded an audit correction. Request both versions, not just a phone explanation that “the system updated it.”

Your review log should identify who supplied the replacement information and what changed. A revision can move a result in either direction; supplying accurate data is the objective.

Not every input belongs to your business. NCCI’s E-1409 methodology update addresses matters including primary and excess losses and credibility parameters. Its applicability is tied to state filings and rating effective dates. A new rule is something to investigate, not a universal explanation for every increase. NCCI experience-rating methodology update.

Ask which approved rating values were used for each worksheet and whether the change in your factor includes a plan-value effect. Request the state and effective date supporting the answer. If an explanation cites a nationwide headline, ask how that headline connects to the actual calculation for your business.

Avoid using a generic online mod calculator to settle the dispute. Without the correct plan, state values, reporting history and complete data, a neatly formatted number can still answer the wrong question.

An acquisition, sale or change in ownership can require a review of which experience belongs in the rating. NCCI provides a specific ownership-reporting process so the appropriate modifications can be produced or revised. A new business name or policy number should not be treated as proof that earlier experience disappeared. NCCI ownership-reporting guidance.

If a transaction occurred, gather the dates, legal entities and ownership documents for your insurance professional. Ask for the determination that explains which entities are included. Do not substitute an affiliate’s more favorable factor for the factor applicable to the business being insured.

Instead of asking only “Why did our rate increase?”, send a short comparison request:

Please reconcile our prior and new issued experience modifications for the stated effective dates. Identify the effects of policy periods entering or leaving, reported claim-value changes, payroll or classification corrections, changed rating values, and any ownership determination. For each material difference, please identify the supporting record and whether a correction or further review is available.

This is suggested request wording, not a bureau form or a claim that every listed item applies. Attach the worksheets through the recipient’s appropriate channel. Set an owner and follow-up date for each unresolved item, especially when a renewal or bid deadline is approaching.

After the record review, use the workers’ compensation calculator only to explore arithmetic with a rate and factor supplied to you. Its subtotal is incomplete and does not calculate an official EMR or final premium. For future operations, our guide to lowering an experience modification separates injury prevention and claims coordination from correcting historical records.

If a client is waiting for documentation, the EMR letter checklist for contractor bids explains how to present the current status without substituting an estimate. For broader coverage questions raised by changing staff, locations or activities, the business insurance assessment can help organize the next discussion.